submitter mrs. lora anderson date: 01/25/2008 ......organization : maps medical pain clinic category...

Submitter : Mrs. Lora Anderson

Organization : MAPS Medical Pain Clinic

Category : Physical Therapist

Issue Areas/Comments

GENERAL

GENERAL attachment

CMS-I 392-FC-311 -Attach-1 .DOC

Page 3 14 of 342

, ,

Date: 01/25/2008

January 28 2008 02:43 PM

December 18,2007

Mr. Keny Weems Administrator

I-. Centers for Medicare and Medicaid Services & Department of Health and Human Services kr. ; t r Attention: MS- 1392-FC b Hubert H. Humphrey Building, Room 445-G i: 200 Independence Avenue, SW

Washington, DC 2020 1 . .

Re: MS-1392-FC

I Dear Mr. Weems:

As a concerned staff member of an interventional pain management physician I would like to comment on multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classifications will hinder patient access.

I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payablh, issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose.was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

I believe that discography should be a separately payable service in the A SC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an ASC setting.

The second issue relates to the update to the conversion factor while ASCs are facing losses, hospitals will still have an upper hand with a better update factor. This should be changed where both update factors are the same.

In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula '

appears to be arbitrary.

I

To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only well-trained qualified physicians and in accredited office settings, thus creating an accreditation standard for offices to perform interventional procedures. This philosophy may be applied to other settings to simply reduce the overuse.

Thank you for theopportunity to comment on the Final Rule.

Lora Anderson MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Jona Annoni


Category : Other Health Care Professional

Issue AreaslComments

GENERAL

I GENERAL attachment

Date: 01/25/2008

15 of 342 January 28 2008 02:43 PM

-

December 18,2007

Mr. Kerry Weems i" Administrator I' Centers for Medicare and Medicaid Services

Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

I Re: MS- 1392-FC

I Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable.issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).



In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula appears to be arbitrary.


Thank you for the opportunity to comment on the Final Rule.

Sincerely,

Joila Annoni MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Mr. Steve Antolick


Category : , Pharmacist


GENERAL

GENERAL

attachment

Page 3 16 of 342

Date: .01125/2008

January 28 2008 02:43 PM

December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS-1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 20201

Re: MS- 1392-FC

Dear Mr. Weems: I


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

I believe that discography should be a separately payable service in the A SC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an.ASC setting.


In addition, CMS should delay implementing the payment cap for office-based procedures. The present fornlula appears to be arbitrary.

To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only w ell-trained qualified physicians and in accredited office settings, thus creating .an accreditation standard for offices to perform interventional procedures. This philosophy may be applied to other settings to simply reduce the overuse.


Sincerely,

Steve Antolick MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Mr. Jim Anway


Category : Nurse Practitioner

Issue AreasIComments

GENERAL

GENERAL

attachment

CMS-I 392-FC-3 14-Attach-1 .DOC

Date: 01/25/2008

Page 3 17 of 342 January 28 2008 02:43 PM

December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 20201

Re: MS-1392-FC

Dear Mr. Weems:

As a concerned staff member of an interventional paln management physician I would like to comment on multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classifications will hinder patient access.

1 am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed Independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that 1s reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).




\ To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only w ell-trained qualified physicians and in accredited office settings, thus creating an accreditation standard for offices to perform lnterventional procedures. This philosophy may be applied to other settings to simply reduce the overuse.


Sincerely,

Jim Anway MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

~ubmiker : Ms. Maggie Ayers

Organization : MAPS Medical Pain Clinics

,,-Category : Other Health Care Professional


1 GENERAL

Date: 01/27/2008

GENERAL . attachment

CMS-I 392-FC-315-Attach-] .DOC

Page 318 of 342 January 28 2008 02:43 PM

December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services .. Attention: MS- 1392-FC

1

!. Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 20201

I Re: MS-1392-FC '

I Dear Mr. Weems:








Sincerely,

Maggie Ayers MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Trisha Ball




GENERAL

GENERAL attachment

CMS- 1392-FC-3 16-Attach-I .DOC

Page 3 19 of 342

Date: 01/27/2008

January 28 2008 02:43 PM

I December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services ~ttention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue,SW ,

Washington, DC 2020 1

Re: MS-1392-FC

Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it.is performed independently in the ASC setting. It was our understanding that in spite 0.f significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervicalor thoracic spine), and a radiology portion that is reported by either CPT. Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

1 believe that discography should be a separately payable service in the ASC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an ASC setting.


In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula' appears to be arbitrary.



Sincerely,

Trisha Ball MAPS ~ e d i c a l Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Kristen Bebeau


Category : Nurse


GENERAL

GENERAL

attachment

4

Date: 01/27/2008


December 18,2007

Mr. Kerry Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

Re: MS-1392-FC

Dear Mr. Weems:

As a concerned staff member of an interventional pain management physician I would like to comment on multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classifications will hinder patient access. . I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

I believe that discography should be a separately payable service in the ASC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an ASC setting.



To avo~d exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only w ell-trained qualified physicians and in accredited office settings, thus creating an accfeditation standard for offices to perform interventional procedures. This philosophy may be applied to other settings to simply reduce the overuse.

Thank you for the opportunity to comment on the Final Rule. .

Sincerely,

Kristen Bebeau MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

I

Submitter : Ms. Sarah Behun

organization : MAPS Medical Pain Clinics



GENERAL

GENERAL

attachments

Page 32 1 of 342

Date: 01/27/2008

January 28 2008 02:43 PM

DEPARTMENT OF HEALTH AND HUMAN SERVICES CENTERS FOR MEDICARE AND MEDICAID SERIVICES OFFICE OF STRATEGIC OPERATIONS & REGULATORY AFFAIRS

Plcase note: We did not receive the at:.,ichment that was cited in this comment. We are not able to receive attachments that have been prepared in excel or zip files. ~ l s o , the commenter must click the yellow "Attach File" button to forward the attachment.

Please direct your questions or comments to 1 800 7 4 3 - 3 9 5 1 .

Submitter : Ms. Peg Beltrand


Category : Nurse

Issue ~reas/Comm'ents

GENERAL

GENERAL

attachments

CMS-I 392-FC-319-Attach-] .DOC

Date: 01/27/2008


December 18,2007

Mr. Keny Wee~ns Administrator

I Centers for Medicare and Medicaid Services 4 Department of Health and Human Services \ .

Attention: MS-1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

Re: MS- 1392-FC

Dear Mr.. Weems:

As a concerned staff member of an interventional pain management physician I would like to comment on'multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classifications will hinder patient access.

I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for d~scography, in lumbar spine) or CPT Cod 62291 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

I believe that discography should be a s e b a t e l y payable service in the A SC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an ASC setting.


In addition, CMS should delay implemen'ting the payment cap for office-based procedures. The present formula appears to be arbitrary. .

To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only w ell-trained qualified physicians and in accredited office settings, thus creating an accreditation standard for offices to perform interventional procedures. This philosophy may be applied to other settings to simply reduce the overuse.


Peg Beltrand MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : MS. Lisa Benedetto


Category : Nurse Practitioner


GENERAL

GENERAL

attachment

Page 323 of 342

Date: 01/27/2008

January 28 2008 02:43 PM


/$ - 2.' C

-4 . . Plchse note: We did not receive the atr:';pchrnent that was cited in this comment. We are not able to receive attachments that have been prepared in excel or zip files. ~ l s o , the commenter must click the yellow "Attach File" button to forward the attachment.

Please direct your questions or comments to 1 800 743-3951.

Submitter : Ms. Rhonda Blomquist




Date: 01/27/2008

GENERAL

GENERAL

attachment

Page 324 of 342. ' January 28 2008 02:43 PM

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS-1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

Re: MS- 1392-FC

Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or

I CPT Code 72295 (discography interpretation and supervision in lumbar spine).


The second issue relates to the update to. the conversion factor while ASCs are facing losses, hospitals will still have an upper hand with a better update factor. This should be changed where both update factors are the same.



1 Thank you for the opportunity to comment on the Final Rule.

Sincere1 y,

Rhonda Blomquist MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN

\ 55433

Submitter : Ms. Jackie Bohannan




GENERAL

GENERAL attachment

Page 325 of 342

Date: 01/27/2008

January 28 2008 02:43 PM


e note: We did not receive the at:.,achment that was cited in this comment. We are not able'to receive attachments that have been prepared in excel or zip files. Also, the commenter must click the yellow "Attach Filerr button to forward the attachment.


Submitter : Ms. Annette Boller

Organization : MAPS Medical Pain Clinics I

Category : Nurse


GENERAL

GENERAL 1' '

attachment

CMS-1392-FC-323-Attach-1.DOC

Page 326 of 342

Date: 01/27/2008

January 28 2008 02:43 PM

December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW

'Washington, DC 20201

Re: MS- 1392-FC

Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injec'tion portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation aqd supervision in lumbar spine).





- ,


Sincerely,

Annette Boller MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW

Submitter : Ms. Wendy Borchart

Organization : MAPS Medical Pain Clinic ,



GENERAL

GENERAL

attachment

Date: 01/27/2008

Page 327 of 342

. J t

, DEPARTMENT OF HEALTH AND HUMAN SERVICES CENTERS FOR MEDICARE AND MEDICAID SERIVICES OFFLICE OF STRATEGIC OPERATIONS & REGULATORY AFFAIRS . v .

~ l c a s e note: We did not receive the at:,$chment that was cited in this comment. We are not able to receive attachments that have been prepared in excel or zip files. Also, the commenter must click the yellow "Attach File" button to forward the attachment.


ir r

1; DEPARTMENT OF HEALTH AND HUMAN SERVICES CENTERS FOR MEDICARE MEDICAID SERIVICES OFFICE OF STRATEGIC OPERATIONS & REGULATORY AFFAIRS

Plcase note: We did not receive the at: ,ichment that was cited in" this comment. We are not able to receive attachments that have been prepared in excel or zip files. ~lso, the commenter must click the yellow "Attach File" button to forward the attachment.


Submitter : Ms. Darcy Brisbin


Category : Physical Therapist


GENERAL

Date: 01/27/2008

GENERAL attachment

I


Mr. Keny Weems I Administrator I .~'v Centers for Medicare and Medicaid Services H

-+ Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G

4..*[ 1

.* \ 200 Independence Avenue, SW Washington, DC 2020 1

t p Re: MS-1392-FC

Dear Mr. Weems:

I As a concerned staff member of an interventional pain management physician I would like to comment on multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classifications will hinder patient access.

I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is perfolmed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

I believe that discography should be a separately payable service in the A SC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize ~nequality between multiple settings and importance of these being done in an ASC setting.

The second issue relates to the update to the conversion'factor while ASCs are facing losses, hospitals will still have an upper hand with a better update factor. This should be changed where both update factors are the same.




Sincerely,

Darcy Brisbin MAPS Medical Pain Clinic 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Diane Budnick


Category : Nurse


GENERAL

GENERAL

attachment

Date: 01/27/2008

,

fi le ~~~TJ~ELECTRONIC%20COMMENTS/ELECTRONIC%2OCOMMENTS/E-Comments/Active%20Files/Missing%2OIeI .at

* .


PLcase note: We did'not receive the at:.,schment that was cited in this comment. We are not able to receive attachments that'have been prepared in excel or zip files. Also, the commenter must click the yellow "Attach File" button to forward the attachment.

& . a -


Submitter : Ms. Megan Budnick



Issue Areas(Comments

GENERAL

GENERAL

Page 33 1 of 342 January 28 2008 02:43 PM

- li ~~:IIITI/ELECTRONIC~/O~OCOM M ENTSIELECr RON lC~o2OCOMMENTS/E-Commen~/Active0/~2OFiles~Missing0/o2Ofie 1 .txt

DEPARTMENT OF HEALTH AND HUMAN SERVICES, CENTERS FOR MEDICARE AND MEDICAID SERIVICES OFFICE OF STRATEGIC OPERATIONS & REGULATORY AFFAIRS

I

I

please note: We did not receive the at:--,-lchment that was cited in i

this comment. We are not able to'receive attachments that hake been prepared in excel or zip files. ~ l s o , the commenter must click the yellow "Attach File" button to forward the attachment.

lease direct lyour questions or comments to 1 800 743-3951.

Submitter : Ms. Mindy Chivers


Category : Other Health car; ~rofessional

Issue AreaslCornments

GENERAL

Date: 01/27/2008

GENERAL attachments

CMS-I 392-FC-329-Attach-1 .DOC


December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS-1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

I Re: MS- 1392-FC

I Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discograpliy procedures have two components: an injection portion that is'reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine),!and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervis~on in lumbar spine).

I believe that discography should be a separately payable service in the ASC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an ASC setting.


In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula appears to be arbi trary.

To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only well-trained qualified physicians and in accredited office settings, thus creating an accreditation standard for offices to perform interventional procedures. This

*

philosophy may be applied to other settings to simply reduce the overuse.


Sincerely,

Mindy Chivers - MAPS Medical Pain clinics

2 104 Northdale Blvd, NW Minneapolis, MN 55433

i I + .

I -+ I. ' 1 .*

'**

.a$.: $ .., (LL

3 e

, E

Submitter : Ms. Mindy Chivers




GENERAL

I

Date: 01/27/2008

GENERAL

attachment


December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS-1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 20201

Re: MS-1392-FC

Dear Mr. Weems:

As a concerned staff member of an interventional pain management physician I wouId like to comment on multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classifications will hinder patient access.

I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two

. components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in '

lumbar spine) or CPT Cod 62291 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

I believe that discography should be a separa;ely payable service in the A SC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an ASC setting.


'. In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula appears to be arbitrary.

h

To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only well-trained qualified physicians and in accredited office settings, thus creating an accreditation standard for offices to perform interventional procedures. This

I

I philosophy may be applied to other settings to simply reduce the overuse.


Sincerely,

Lindsey Christensen MAPS Medical Pain Clinics 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Laurie Curtis




GENERAL

GENERAL

attachment

CMS-I 392-FC-331-Attach-1.DOC

Date: 01/27/2008


December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services

"4 , Department of Health and Human Services p:, : g, . Attention: MS- 1392-FC

Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

I Re: MS- 1392-FC

Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290.(Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).

I believe that discography should be a separately payable service in the A SC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails'to recognize inequality between multiple settings and importance of these being done in an ASC setting.

The second issue relates to the update to the conversion factor while ASCs are facing losses, hospitals will still have I an upper hand with a better update factor. This should be changed where both update factors are the same.

: In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula appears to be arbitrary.



Jamie Cottom MAPS Medical Pain Clinics 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Jamie Cottom


Category : Health Care Provider/Association


GENERAL

GENERAL

attachment

Date: 01/27/2008


December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1 .

Re: MS- 1392-FC

I Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology portion of discography when it is performed independently in the *

I HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant,cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two , components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in , lumbar spine) or CPT Cod 62291 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).


The second issue relates to the update to the conversion factor while ASCs are facing losses, hospitals will still have , an upper hand with a better update factor. This should be changed where both update factors are the same.

I In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula appears to be arbitrary.

1

To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only w ell-trained qualified physicians and in accredited I

office settings, thus creating an accreditation standard for offices to perform interventional procedures. This , philosophy may be applied to other settings to simply reduce the overuse.

, Thank you for the opportunity to comment on the Final Rule. I

Jamie Cottom MAPS Medical Pain Clinics 2 1 04 Northdale Blvd, NW Minneapolis, MN 55433

\

Submitter : Ms. Laurie Curtis




GENERAL

GENERAL

attachment


f . '

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Date: 01/27/2008

Page 336 of 342 January 28 2008 02:43 P M

December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

Re: MS-1392-FC

Dear Mr. Weems: .


1 am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to dmscography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to'apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 62291 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).






Sincerely,

Laurie Curtis MAPS Medical Pain Clinics '

2 104 Northdale Blvd, NW Minneapolis, MN

. . 55433

Ms. Jaime Donald Submitter :

Organization : MAPS Medical Pain Clinics,



GENERAL

GENERAL

attachment

Date: 01/27/2008



December 18,2007

Mr. Kerry Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS- 1'392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 2020 1

Re: MS-1392-FC

Dear Mr. Weems:





I

If In addition, CMS should delay implementing the payment cap for office-based procedures. The present formula a - appears to be arbitrary. b .

To avoid exponential increases in procedures performed in all settings specifically in-office settings, CMS should establ~sh that these procedures should be performed by only well-trained qualified physicians and in accredited office settings, thus creating an accreditation standard for offices to perform interventional procedures. This philosophy may be applied to other settings to simply reduce the overuse.

r I Thank you for the opportunity to comment on the Final Rule.

Jaime Donald MAPS Medical Pain Clinics 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Laura Dresser


,i ' Category : Other Health Care Professional


1.- GENERAL

GENERAL

attachment


Page 338 of 342

Date: 01/27/2008

January 28 2008 02:43 PM

i December 18,2007

1 Mr. Keny Weems 1

Administrator Centers for Medicare and Medicaid Services Department of Health and Human Servlces Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW Washington, DC 20201

Re: MS- 1392-FC

Dear Mr. Weems:

As a concerned staff member of an interventional pain management physician I would like to comment on multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classificat~ons will hinder patient access.


1 believe that discography should be a separately payable service in the ASC as it is not treated as a surgical procedure eligible for separate payment under the payment system. This payment policy fails to recognize inequality between multiple settings and importance of these being done in an ASC setting.

The second issue relates to the update to the conversion factor while ASCs are facing losses, hospitals will still have , r . an upper hand with a better update factor. This should be changed where both update factors are the same.

In addition, CMS should 'delay implementing the payment cap for office-based procedures. The present formula appears to be arbitrary.



Sincerely,

Laura Dresser MAPS Medical Pain Clinics 2 104 Northdale Blvd, NW Minneapolis, MN 55433

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C Submitter : Ms. Mary Dubel Date: 01/27/2008 'i t', Organization : MAPS Medical Pain Clinics 1


k+% Issue AreaslComments , I % GENERAL

GENERAL

u attachment


December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS-1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, S W Washington, DC 2020 1

Re: MS- 1392-FC

Dear Mr. Weems:

As a concerned staff member of an interventional pain management physician I would like to comment on multiple disparities which exist between ASC setting and HOPD setting. These disparities and the CMSs new proposals and classifications will hinder patient access. \

I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to discography. CMS pays separately for radiology of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 62291 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).


/





Sincerely,

Mary Dubel MAPS Medical Pain Clinics 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Ms. Amie Ecker 9

e Organization : MAPS Medical Pain Clinic


[ ~ S S U ; ~ r e a s / ~ o m m e n t s L T - B

GENERAL

' Date: 01/27/2008

GENERAL

atta,chment

CMS-I 392-FC-337-Attach-1.DOC

Page 340 of 342 '

January 28 2008 02:43 PM

December 18,2007

Mr. Keny Weems Administrator Centers for Medicare and Medicaid Services Department of Health and Human Services Attention: MS- 1392-FC Hubert H. Humphrey Building, Room 445-G 200 Independence Avenue, SW

Re: MS- 1392-FC

Dear Mr. Weems:


I am concerned about status indicator for CPT Codes 72285 and 72295 and non-payable issue which is related to d~scography. CMS pays separately for radiology portion of discography when it is performed independently in the HOPD setting, however it does not pay separately for the very same service when it is performed independently in the ASC setting. It was our understanding that in spite of significant cuts for interventional pain management the whole purpose was to apply the standards uniformly but it does not seem so. Discography procedures have two components: an injection portion that is reported by either CPT Code 62290 (Injection procedure for discography, in lumbar spine) or CPT Cod 6229 1 (Injection procedure for discography in cervical or thoracic spine), and a radiology portion that is reported by either CPT Code 72285 (discography interpretation and supervision in cervical spine) or CPT Code 72295 (discography interpretation and supervision in lumbar spine).




I

To avoid exponential increases in pro~edures performed in all settings specifically in-office settings, CMS should establish that these procedures should be performed by only well-trained qualified physicialis and in accredited office settings, thus creating an accreditation standard for offices to perform interventional procedures. This philosophy may be applied to other settings to simply reduce the overuse.


Sincerely,

Amie Ecker MAPS Medical Pain Clinics 2 104 Northdale Blvd, NW Minneapolis, MN 55433

Submitter : Mr. Jeremy EUis



Issue AreaslComments i

?. GENERAL

i. f

GENERAL

j' attachment r

Page 341 of 342

Date: 0112712008

January 28 2008 02:43 PM

DEPARTMENT OF HEALTH AND HUMAN SERVICES CENTERS FOR MEDICARE AND MEDICAID SERIVICES

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Pldse.noee: We -%. did not receive the a'P:l..;.%chment that was cited in this comment. w e ire not able to receive attachments- that have been

: prepared inexcel or zip files. '~lso. the commenter must click the , yellow "Attach File" button fo forward the attachment.

Please direct your questions or comments to 1 800 743-3951

CMS-1392-FC-339

Submitter : Ms. Mary Esslinger Date: 01/27/2008


Nurse Practitioner

, Issue AreaslComments

GENERAL

GENERAL

attachment



I

F P16 _.se note: We did not receive the at:.,%chment that was cited in this comment. We are not able to receive attachments that have been prepared in excel or zip files. ~lso, the commenter must click the yellow "Attach File" button to forward the attachment-

Please direct your que,stions or comments to 1 800 743-3951.

submitter mrs. lora anderson date: 01/25/2008 ......organization : maps medical pain clinic category...

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